MEDIA RELEASE
Contact: Brenna Cannon
Email: info@shelterjh.org
FOR IMMEDIATE RELEASE
ShelterJH endorses housing champions in local election
Local housing advocacy organization ShelterJH announced endorsements for Town Council, County Commission, and Sheriff candidates today.
“This 2018 election is a great reminder that we all need to vote all the way down the ballot – local elections will have a huge impact on our neighbors, especially our most vulnerable neighbors,” said Mary Erickson, ShelterJH board chair.
For the first time, ShelterJH is endorsing housing champions in three local elections. We sent all local candidates a questionnaire about housing; you can read what the candidates who responded said here. Then the ShelterJH board met, with input from active members, and discussed all candidates based on their answers to the questions and what we know of their public actions for housing. Our criteria included our judgement of their commitment to affordable housing in general; their commitment to our most vulnerable neighbors in particular; their likely effectiveness; and their alignment with our policy priorities such as tenant protections and sustainable public funding for housing ⅔ of our community.
Town Council
It was not easy to pick only two of the four candidates for Town Council. All four have promised action on housing our workforce, and Don Frank is an incumbent who has been a part of good decisions over the last few years – we are grateful for those actions, but given the gravity of our housing crisis, we need the Council to go beyond good work to truly outstanding work and new levels of leadership. In the end, it was clear that two candidates are truly focused on housing as a core priority. As a housing organization, our mission is to identify leaders who will prioritize solving our housing crisis – especially for our lower-income community members.
Jessica Chambers has demonstrated a personal and public commitment to housing, especially those most in need. As she wrote in her response to our questionnaire: “We need public investments in human services, child care and early education, and housing. We need a livable wage for workers… Overall, I will make decisions based on the best interests of the working people in Jackson with regard to housing and beyond.”
Arne Jorgensen has been a housing leader for 30 years. He was a founder of the Housing Trust and has been involved in countless housing initiatives over the years. He wrote, “if elected to serve on the Jackson Town Council I will encourage my fellow Councilors to dedicate the resources necessary until measurable progress on this issue is made; until this issue is truly prioritized, it will continue to fall by the wayside. It has become more and more clear to me that we will not be successful without being willing to invest in real solutions.”
Both Jessica & Arne have expressed a clear commitment to prioritizing housing, including through density in town, new public funding, and creative uses of town-owned land.
County Commission
We found the County Commission candidates represented a greater range of focus on affordable housing: some candidates are clearly committed to housing our workforce, while others have other priorities. Some say they believe in affordable housing but also believe the “free market” will provide it, and refuse to consider public funding – showing a clear lack of understanding of our local conditions. Although you can vote for up to three candidates, we have identified two housing champions: Seadar Rose Davis and Luther Propst.
Seadar Rose Davis is committed to using public resources for working-class people. In her answers to our questionnaire, in addition to expressing her openness to a variety of housing strategies, she stated: “I will strongly fight to improve access to affordable and safe child care, for robust public health services, and for strong partnerships with our human services sector.“
Luther Propst has a career’s worth of experience working with Western small town communities, trying to balance economic growth with familiar community values like open space protection, and – most important for us – providing ample housing for people who work there. Luther wrote that some of his principles include: “Focus on both supply and demand. In 2017, Teton County experienced 3.5% job growth; at that rate, the number of jobs doubles in 20 years. That rate of growth compromises the vision of Teton County’s comprehensive plans, our community values and character, and our wildlife. Prioritize providing the full range of affordable housing, including rentals, rather than land use changes that create more demand for housing. Foster housing partnerships among local governments, employers, landowners, lenders, and both private and non-profit developers.“
We believe Seadar and Luther will be the strongest voices for affordable housing on the county commission.
Sheriff
We also invited candidates for Teton County Sheriff to answer our questionnaire and tell us why they would be the best candidate for housing and for our working and middle classes. As a large employer, the sheriff directly influences housing critical service providers in their department. The sheriff also sets policy and practices related to protecting and serving our most vulnerable community members. We believe Matt Carr has a proven history, and ongoing commitment, to leading our law enforcement from a humane and solutions-oriented perspective.
These are our endorsements. We encourage you to research and meet the candidates, and most of all – remember to vote!
ShelterJH builds political power so that all our workers can have secure housing in Jackson Hole. We are a membership organization created by Jackson’s middle-class and working-class workers. We are especially focused on solutions for our neighbors living with the most housing insecurity. As a 501(c)4 nonprofit instead of the typical 501(c)3, we can endorse, oppose, and support candidates – and help get and keep great housing champions in office. Join us: www.shelterjh.org
ShelterJH is hiring grassroots organizers!
Job title: ShelterJH grassroots organizer(s) – multiple positions available
About ShelterJH: we are a membership organization working to ensure that all who work in Jackson can have a home here. We all dream of a better life. We work hard and make sacrifices to try to meet our goals here in Jackson, the community we love. As a community, we rely on each other in numerous ways. When one of us struggles, we all suffer – our families, our friends, our employers, and Jackson as a whole. To ensure we can all do more than merely survive here, we’re committed to making Jackson livable for everyone. This is our home, and we want it to stay interesting, lively, and the Jackson Hole we know and love.
ShelterJH is a 501(c)4 membership organization, unlike your average nonprofit. All of our money comes from people like us, instead of focusing on wealthy donors. We’re completely independent and free to work for the best interests of tenants and workers. Members elect our board and give input on big decisions at our annual member meeting. We can support candidates to help keep great housing champions in office.
Job description:
The grassroots organizer(s) will lead a ShelterJH activism and membership drive during the 2018 election season. The local elections are an ideal time to spread our message and get more community members involved in our work as volunteers, activists, and members. The organizer(s) will get out in the community, with a special focus on their own communities and networks, and get more people involved. ShelterJH board members will manage and mentor the organizers.
Hours and compensation:
Multiple part-time positions are available, adding up to an average 16 hours / week total (so we could hire two people at 8 hours / week, or three people at smaller amounts, etc). We want this position to work for busy people who already are working full-time or more. These jobs are excellent training for aspiring grassroots organizers / mobilizers. Pay is $15 / hour with additional bonuses for successfully growing our member base.
Job duties:
- Member / activist canvass: invite more people to join ShelterJH as members ($20 / year dues, sliding scale) and activists. Utilize community events (tabling), your own networks, door-to-door canvassing, and our list of interested people from previous events to find people who want to sign up. We especially want candidates who can engage young and/or Latino folks. – estimated 4-8 hours / week
- Turnout: mobilize your networks to show up at election events like candidate forums; Town Council meetings; etc. – estimated 1-2 hours / week
- Event/election coordination: we would like one organizer to take on additional administrative duties, including coordinating events and our electoral work (questionnaire, candidate interviews, endorsements, ads, etc) – estimated 4-5 hours / week
Qualifications:
- Friendly, outgoing, good with people
- Highly motivated and self-starter
- Bilingual preferred (English / Spanish)
- Experience in canvassing and elections is preferred
- Good written communication and organizational skills (for administrative role)
To apply:
Contact info@shelterjh.org with cover letter and resume, or any questions. Deadline: August 20 (applications accepted and interviews scheduled on a rolling basis.)
Affordable Housing Rules and Regulations
April 11, 2018
The town and county invited for further public comment on some of the details of their most recent drafting of rules and regulations for affordable housing in our community. Below are some of our thoughts and opinions on the staff’s recommendations and the general discussion of housing in our community! We are stronger together, not divided.
Dear Mayor Muldoon, Town Councilors, and County Commissioners:
Thank you for the opportunity to comment on your joint housing rules and regulations, and thank you and your staff for a tremendous amount of hard work on these important subjects.
ShelterJH is a membership organization that works to ensure all who work in Jackson can have a home here. When people move out or commute, we lose critical service providers on-site, and we lose volunteers and active members of our community. Therefore, as we consider changes to housing rules, regulations, and zoning, we should always ask what the changes will do for our workers and community – especially our community members in the most vulnerable situations.
We have one high-level comment, and then comments on a few topics that we understand are still being discussed.
Overall, we believe the whole discussion of housing rules & regulations has been framed in a very limited way: Currently, affordable homes are viewed as a gift from our community to a few deserving individuals who have earned the homes through their merit, hard work, and type of work – and therefore our regulations should be very strict to make sure that only the most deserving people get and keep affordable housing. This whole frame misses the point. It’s not about the individuals at all – it’s about what kind of community we want to be. We believe a diverse community is a better community – and that we all benefit when our workers can live here. We aren’t “giving” homes to people – we’re creating opportunities that don’t otherwise exist for a diverse community that benefits all of us. If we don’t create affordable homeownership and rental opportunities, we’ll end up an empty husk of a resort town – and none of us want that. Seen in this light, the purpose of these rules and regulations should be to set up simple and streamlined opportunities to ensure a diverse community of local workers. Overall, we believe the current proposal is overly regulated, overly punitive, and overly expensive to administer. Please use our tax dollars on building community rather than surveillance of affordable homeowners and tenants.
Occupancy requirements
Your current draft regulations add more restrictions to the size and types of households that can apply for different sizes of units. We ask that you base occupancy on number of persons in the household and not distinguish between adults and dependents. Based on discussions with two Fair Housing experts, we believe that restricting applications based on familial status (i.e. whether children are in the household or not) violates Fair Housing rules. Just as one example: a household of 2 should be able to apply for a 2-bedroom unit, regardless of what kind of family that is (a couple or a single parent with a child). Adding more rules makes this more restrictive and complicated. Please do not discriminate based on family / household make-up.
Lottery / drawing process
We are glad to see the new lottery process has been streamlined to only one “bucket,” so everyone who applies actually has a chance to win. This is a notable improvement over the old system. The goal should be creating a simple and equitable system that can retain local employees. Putting in more applications is irrelevant to our goal of retaining a diverse local workforce and is unnecessary. Increasing entries based on the amount of time you’ve lived here adequately provides priority for longevity in the community. Please do not add “number of past applications” to the drawing process.
Renting rooms in an affordable/employment home
When it comes to renting rooms, our goal should be to fill all available rooms with qualified employees, and to simplify the rules – not to generate revenue for the housing program. There are currently empty bedrooms, often the result of changing family status – why not let homeowners rent them to qualified renters? It is a cost-effective and environmentally sensitive way to get some of our employees in a safe and healthy living situation. To your staff report questions:
- Yes, please allow rentals. Especially in employment-based homes without income restrictions, there is no reason to prohibit roommates. And in both employment-based and affordable homes, allowing roommates who also work here further helps house our workforce – which is our goal.
- The annual fee should be a simple and low flat fee of $100. Again, the goal isn’t to fund our housing program – it is to get more people in affordable housing. Yes, that takes staff time – but that’s why we fund the Housing Department with existing funds. Staff should not be involved in collecting rent – keep it simple.
- Maximum rents should be very affordable, and linked to maximum rents in public rental units. We suggest that all rented rooms (regardless of the category of the home) have a maximum rent that is affordable to 1 person at 50% AMI. (Option 3 at $460 seems most appropriate.) We do not support splitting rent with the housing department. Again, the goal isn’t to raise money, it’s to house more people. If a homeowner only gets half the rent, there’s much less incentive to rent your room to someone who needs it – and it’s more costly to administer.
Overall, please choose the policy options that are the simplest and do the best job at housing our local workers – especially those in most need (people earning below 50-60% of area median income).
Thank you for your consideration,
Mary Erickson
Chair
ShelterJH
The Town & County are updating the rules for both housing mitigation requirements (how much affordable housing developers have to include in their projects) and housing rules & regs (who gets to live in our affordable homes, and what strings are attached). These are part of their “Engage2017” work and there’s a ton of info on their website.
Town & county elected representatives met last week and gave preliminary direction on how they want to address all the important topics in these two projects. We are extremely encouraged by their decisions on some of our “top 6 priorities” that we listed below. Please thank them for taking steps in the right direction, especially for agreeing to stop asking renters for immigration documentation.
The town & county have one more joint meeting next Monday November 13 to finalize their policy direction for both topics. We hope to see you there! If you can’t make it in person, email our representatives ahead of time – council@townofjackson.com and commissioners@tetonwyo.org.
OUR TOP PRIORITIES (in short form)
- Mitigation: instead of the current complicated proposal that leaves out seasonal employees, please use a simpler setup: “developers should mitigate for 65% of all employees – both year-round AND seasonal – and re-do the Nexus Study so we have up-to-date data.” And, please require 1-for-1 replacement of all workforce units destroyed by redevelopment.
- Rules & regs: thanks for moving away from asking renters for immigration documents!
MORE DETAIL…
Housing rules & regs: overall, simplify the rules, and don’t discriminate either intentionally or unintentionally against most vulnerable community members.
- Don’t discriminate against renters based on immigration status. The comprehensive plan calls for housing 65% of all local workers, not just documented workers. Unlike with employment, no law requires asking about documentation for housing – it’s just a policy decision, and one that is currently excluding a large number of our community members who have lived here for decades, work hard, and pay taxes. Please remove immigration status from your rental criteria. (Policy Question 1.) >>> Almost all our representatives agreed with this – please thank them!
- Owners should be able to rent rooms to other local workers. For employment-based homes without income restrictions, there is no reason to prohibit roommates. And if roommates do not push an income-limited owner over the income limit, that should be allowed too. Ultimately, allowing roommates who also work here further helps house our workforce. (Policy Question 9.) >>> Our representatives asked staff to bring more info back on Monday. Keep asking for this!
- Simplify the lottery process by entirely removing preferences and points. The current system is complex and also gives extra weight to people who have the ability to volunteer – excluding service workers forced to work multiple jobs just to provide for their families. (Policy Question 10.) >>> Our representatives may change the system but still need to hear from more people that our housing should be available for all our workers in an open and fair lottery – not based on an idea of “earning” our way in.
Housing mitigation / requirements: overall: simplify the program and fully mitigate for 65% of new employee generation
- Our housing mitigation program should generate enough units to actually *keep up* with new jobs created, and house 65% of our new employees. This will likely mean increasing mitigation rates, as well as applying them for both year-round and seasonal jobs, for all jobs paying below 200% area median income, and on commercial and residential projects. >>> The new proposal may do a better job “keeping up” with job growth, but it’s hard to know because there’s no math showing how it connects to our 65% community goal. We strongly recommend a simpler system that includes both year-round and seasonal employees and requires developers mitigate for 65% of all full-time equivalent employees (FTEs).
- Simplify the program by reducing the number of use categories and removing the change-of-use fee – instead, just charge an averaged rate initially. >>> This helps make the previous point work better.
- Require 1-for-1 replacement of any existing units lost to redevelopment. In addition to “keeping up” with the new development, we also need to replace affordable/workforce units that are bulldozed before that new development is built – and we should require these be replaced 1-for-1. Otherwise, we’re just digging our hole deeper. >>> Our elected representatives are considering this idea, but need to hear more support from all of us!
FULL COMMENTS
Rules & regs letter:https://shelterjh.org/2017/10/change-affordable-housing-rules-regs
Mitigation letter:https://shelterjh.org/2017/10/will-housing-mitigation-help-us
We’ve been closely tracking the housing mitigation and housing rules & regs updates in the town and county’s “Engage2017” planning updates. Town Council and County Commission are getting input that opposes our goals of fair housing for all, and more affordable and workforce housing … so hearing from community members who support housing is critical. The town & county have a joint meeting on Monday October 30 about both mitigation and the housing rules & regulation. We hope to see you there!
UPCOMING SCHEDULE
Oct. 30: Joint Town Council and County Commissioners meeting to consider alternatives and develop a draft policy direction. 5 p.m., Town Hall. May be continued to Nov. 1-2 if necessary. Public comment to be accepted.
Nov. 3: Release of draft policy direction. 5 p.m., Town Hall.
Nov. 13: Joint town and county meeting to finalize policy direction. 5 p.m., Town Hall. Public comment to be accepted.
OUR TOP PRIORITIES
Housing rules & regs: overall, simplify the rules, and don’t discriminate either intentionally or unintentionally against most vulnerable community members.
- Don’t discriminate against renters based on immigration status. The comprehensive plan calls for housing 65% of all local workers, not just documented workers. Unlike with employment, no law requires asking about documentation for housing – it’s just a policy decision, and one that is currently excluding a large number of our community members who have lived here for decades, work hard, and pay taxes. Please remove immigration status from your rental criteria. (Policy Question 1.)
- Owners should be able to rent rooms to other local workers. For employment-based homes without income restrictions, there is no reason to prohibit roommates. And if roommates do not push an income-limited owner over the income limit, that should be allowed too. Ultimately, allowing roommates who also work here further helps house our workforce. (Policy Question 9.)
- Simplify the lottery process by entirely removing preferences and points. The current system is complex and also gives extra weight to people who have the ability to volunteer – excluding service workers forced to work multiple jobs just to provide for their families. (Policy Question 10.)
Housing mitigation / requirements: overall: simplify the program and fully mitigate for 65% of new employee generation
- Our housing mitigation program should generate enough units to actually *keep up* with new jobs created, and house 65% of our new employees. This will likely mean increasing mitigation rates, as well as applying them for both year-round and seasonal jobs, for all jobs paying below 200% area median income, and on commercial and residential projects.
- Simplify the program by reducing the number of use categories and removing the change-of-use fee – instead, just charge an averaged rate initially.
- Require 1-for-1 replacement of any existing units lost to redevelopment. In addition to “keeping up” with the new development, we also need to replace affordable/workforce units that are bulldozed before that new development is built – and we should require these be replaced 1-for-1. Otherwise, we’re just digging our hole deeper.
FULL COMMENTS
Rules & regs letter: https://shelterjh.org/
Mitigation letter: https://shelterjh.org/2017/10/will-housing-mitigation-help-us
The town and county asked for public input on a series of questions about our Housing Rules & Regulations as part of their Engage2017 planning work. The ShelterJH policy team dug deep into the questions and wrote the following letter to our elected representatives. We hope it helps explain what mitigation is and how it can help. Make sure to share your ideas with the Town Council and County Commission! Contact us with any questions at info@shelterjh.org, and please become a member and build our power today!
RE: Housing Rules & Regulations
Dear Mayor Muldoon, Town Councilors, and County Commissioners:
Thank you for the opportunity to comment on your joint housing rules and regulations. ShelterJH is a membership organization that works to ensure all who work in Jackson can have a home here. As we consider changes to housing rules and regulations, we should always ask what the changes will do for our workers and community – especially our community members in the most vulnerable situations.
We believe it is important to have clear rules and regulations governing the “who” and “how” of rental and ownership homes provided by the public sector to ensure that policies are equitably serving all working households. The current rules and regulations have evolved over the last 22 years to address shifting needs and implement diverse programs established by the Board of County Commissioners and Town Council. This patchwork of rules and regulations has:
- Contributed to the complexity of the housing program creating management challenges and increased staffing requirements
- Reduced transparency, created misconceptions and made it difficult for residents to understand; and
- Is likely disproportionately serving different demographics – maybe not to the benefit of our most vulnerable neighbors.
We believe this exercise is a great start to understand community perceptions about the existing housing program, explain how the current program operates, and learn about what is being done in comparable communities. We also believe the next step of this work should be undertaken by the Joint Housing Authority Board because most of these questions are technical and deserve scrutiny by those that have expertise and will be implementing these rules and regulations.
This next step should include an analysis of the existing housing program to understand through data instead of perceptions whether the existing rules and regulations have been effective at achieving the intended housing program goals. Because there is no data in the materials to date, it is impossible to determine whether there are problems with the status quo, or if any of the proposed alternatives will actually improve the housing program.
Additionally, the basis for the proposed alternatives has some shortcomings. The term “best practices” of comparable communities is misleading because the comparison is of the practices used by these communities without an analysis of whether the practices are effective. Additionally, the reliance on Aspen as a model is troubling because the Aspen Pitkin County Housing Authority is actually right now undertaking a major overhaul of their rules and regulations based on a thorough study of their housing program.
In order to work within this Engage2017 process, we provide comments for your consideration that distinguish between the various housing programs, such as Affordable, Employment-Based, and Accessory Residential Unit, where appropriate. Our comments are intended to simplify the existing housing framework, make the public market work with more efficiency and ensure fairness.
1. What should the employment criteria be to rent or purchase a restricted home?
1A: Modify the employment criteria to make them more user-friendly while adhering to the Fair Housing Act:
- Eliminate the employment preferences in the lottery system; they are complex to manage, difficult to understand, confusing to potential buyers/tenants, and they are discouraging to new employees. (See also question 10.)
- It is crucial to define what “local workforce” means. We support your definition: working at “a business located within Teton County, holding a business license with the Town of Jackson, or one that can provide other verification of legal business status in Teton County, WY”.
- Telecommuters have a choice to live anywhere and should not be eligible for any housing programs subsidized by the public sector. There is a limited supply of this housing and occupancy should be optimized by restricting to local workers or classes protected by the Fair Housing Act and seniors.
- We suggest that you remove immigration documentation requirements from rental units: currently “at least one member of the household [must be] a U.S. citizen or lawful permanent resident (Green Card).” While that may make sense for ownership units, where lenders require immigration documentation for a mortgage and sellers of deed restricted homes can be impacted by the inability of a buyer to obtain a loan, rental units do not have this challenge, and our community goal is to house the local workforce in our valley. We should be concerned with whether the renters are employed in the valley and within the income limits that we require for everyone – and that’s it.
- We support allowing families to buy affordable/employment homes if at least one adult household member is documented (e.g. citizen / legal permanent resident). While we recognize there are reasons to require that our homeowners have documents (such as obtaining leases, and the security of knowing their employment situation), we do not believe our community should be in the business of immigration document inspection for all household members. If any adults qualify, let’s not worry about other household members.
2. What kind of assets should be allowed and/or counted, and how much is the limit?
2G: This is a technical question demonstrated by 7 options for consideration and is beyond the scope of appropriate public outreach. The Joint Housing Authority Board should provide a policy recommendation based on technical analysis of the current asset limit and calculation methodology. Data would enable answers to several questions, including:
- How many households are denied access because of the current asset cap?
- How many households would be impacted by a change in the asset cap?
- What percentage of household assets are retirement savings?
- What is an appropriate asset cap to allow equal access to restricted housing inventory?
We offer some suggestions for consideration to the options proposed:
- Ownership of another home or mobile home within 150 miles should not be allowed while owning a deed restricted home. Upward mobility is achieved by offering an opportunity for safe, secure, and affordable housing with a share of the equity at time of resale.
- Ownership of a home or mobile home at time of qualification for an “Affordable” home should be allowed to enable households to move back into the valley from our bedroom communities and to move into more suitable housing to meet their household needs.
- Ownership of a home or mobile home at time of qualification for a rental product or an “Employment-Based”, “Attainable” or “Workforce” unit should not be allowed. Special circumstances can be addressed through the relief process.
- If ownership is allowed in any of the programs, the income from the residential property should be used in calculating household income and the equity in the home should be used to determine household assets.
- Implement a set asset cap, such as $200,000, that applies to all “Affordable” categories.
- Eliminate retirement savings that are not used to purchase the home from the calculation of assets so households are not ineligible because they have been financially prudent by saving for retirement.
3. How many months out of a calendar year should a household be required to occupy a restricted unit?
3B&D: The intent of using public resources for restricted housing is to provide a safe, decent and affordable place for local workers to live.
- The occupancy requirement should be 11 months out of the year for the deeply subsidized “Affordable” homes – in order to reduce competition for lower priced homes from those that choose to work fewer months out of year, and recognize the unique character of Jackson’s workforce that often hold seasonal jobs.
- The requirement should be 9 months per year for the Employment-Based and Workforce homes, as those programs are more flexible by design, and not targeted to low-income workers.
4. What livability standards, if any, should apply to restricted units?
4G: This is another technical question demonstrated by 7 options for consideration and beyond the scope of general public outreach. The Joint Housing Authority Board should provide a policy recommendation based on technical analysis of the current asset limit and calculation methodology.
We offer some suggestions for consideration to the options proposed:
- Rental units designed for seasonal employees, often in the form of dormitories, do not have the same storage needs as units for long-term employees.
- Standardize the size requirements between long-term rental and ownership units. Allow flexibility for design creativity that does not compromise livability.
- Maximum sizes should be implemented to encourage more units instead of larger units, if mitigation is based on square footage.
- Energy Star appliances are competitively priced and widely available. Use of Energy Star appliances should be required to decrease the operational costs, which impacts long-term affordability.
- Consider an incentive that allows developers to raise the maximum sales prices if they incorporate elements that lower costs to operate and maintain the home compared to current building codes.
5. What percentage of a household’s income should be spent on housing?
5A: Determining an affordability standard is a common challenge for policy makers in resort communities. Selecting a measure that minimizes the subsidy to create the unit, while ensuring that housing is a source of financial stability to the occupant is a delicate balance. The 30% ratio of income-to-housing cost is the most common figure used in comparable communities.
The Joint Housing Authority Board should provide a policy recommendation based on technical analysis of the current methodology. Data would enable answers to several questions, including:
- How many households are getting homes that could afford to pay more?
- How many households are in homes that are unaffordable?
- How many households have been denied housing because they exceed the debt to income ratio limit?
We offer some suggestions for consideration to the options proposed:
- The Affordable homes have qualifying income ranges designed to prevent households from earning too much to qualify for certain homes.
- The minimum debt to income ratio discourages households from being financially sound and carrying unnecessary debt.
- The maximum debt to income ratio was implemented prior to the financial crisis when banks were offering high risk loans based on stated incomes and high debt to income ratio. This standard should remain because it protects the community asset by offering a method to ensure the buyer can afford the home and lessening the risk of foreclosure. It also ensures that the buyer is eligible for a conventional loan.
- Consider lowering the percentage of income spent on housing for “Affordable” Category 1 households. Households earning $100,000 per year have much more left over after paying 30% of their income for rent or mortgage to cover other necessary costs than do households earning less than $30,000 per year. The flat 30% ratio does not take into account the varying ability for households at different income levels to afford non-housing essentials such as food, clothing, transportation, healthcare and childcare.
6. When should a household have to qualify for a rental or ownership home?
6D: 6B is recommended to streamline the requalification process, but consider a longer time-frame for requalification of rental units to between 2-3 years to reduce management costs and increase renter stability. Requalification on “Affordable” ownership should not be required as long as owning other residential real estate is prohibited (see question 2).
7. How should the sale/rent price be set?
7G: This is a technical question and the Joint Housing Authority Board should provide a policy recommendation, based on an analysis of the current program. It is unclear whether there is a problem with the current system and if any of the proposed alternatives and data would improve it. We recommend answering several questions, including:
- Are the homes affordable to the current occupants?
- Are households able to pay more for housing? If so, how much?
- Are households paying too much for housing? If so, how much?
We offer some suggestions for consideration to the options proposed:
- Make sure the methodology to calculate initial sales prices and rental rates is clear, transparent, and easy to update.
- Set initial sales prices for Employment-based units and Workforce ownership units to serve households earning at or below 200% AMI.
- Interest rates significantly affect the affordable purchase price of homes. For every 1%-point rise, the purchasing power of a household decreases by about 10%. This needs to be considered when establishing prices for new affordable homes.
8. How should restricted ownership homes be valued at resale?
8A: Maintain status quo until an analysis can be completed to evaluate the inventory of affordable housing and see which alternative is creating affordable outcomes over time. There is an opportunity to analyze these alternatives because the housing program has been in existence for 25 years and there is a supply of affordable housing units to evaluate. This is in contrast to arbitrarily selecting alternatives without basis.
9. How should renting or subletting be handled?
9C: Owners should be able to rent rooms to other local workers. This especially makes sense for owners of employment-based homes. Currently, no homeowners may have roommates. This may make sense in income-limited (e.g. Category 1-3) homes, where roommates put household income over the limit. However, for employment-based homes without income restrictions, there is no reason to prohibit roommates. And if roommates do not push an income-limited owner over the income limit, that should be allowed too. Ultimately, allowing roommates who also work here further helps house our workforce.
10. How should the buy/sell process work?
10 None of the Above: Streamline and simplify the lottery system by removing all preferences (including for critical service providers and for length of time living here). This will allow access to all members of the workforce in an equitable manner, which is the appropriate use of local, state and federal tax dollars as well as developer exactions. It also makes the selection process transparent, easy to understand, and far less costly to administer. Finally, instead of being perceived as a system where people are rewarded for “earning” affordable housing because of how much they’ve contributed, it is a simple and equitable system that – once people are in affordable homes – ensures they can stay and contribute to our community.
11. What types of relief should be allowed from the Rules & Regulations?
11D: Formalize the appeals process, clarify the process and set standards for making determinations. Make the appeals process and determination criteria available to the public in a transparent manner.
12. How should new Rules & Regulations be applied to existing units?
12E: The Special Restrictions should at a minimum include terms and conditions related to occupancy, use and resale. Instead of relying on public comment, legal advice should be sought to determine what needs to be in the Special Restriction or Ground Lease to protect the community asset, what can be contained in the Rules and Regulations, and which set of Rules & Regulations must be referenced. If a rental product, the relevant and current Rules & Regulations should be incorporated in the lease agreement.
Thank you for your consideration and these technical issues. Again, we respectfully recommend that the next step is a technical, data-driven analysis of the existing housing program with review by and recommendations from the Joint Housing Authority Board. Please be in touch with any questions if we can help.
Sincerely,
Christine Walker
Policy Team Chair
ShelterJH
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